Federal Communications Commission Form 471 Filing Window Closed: What to Do if You Missed the Deadline

If you missed this deadline, you have a two-week window from April 29 to file and certify your FCC Form 471 in the E-rate Productivity Center (EPC) of the Universal Service Administrative Company’s (USAC) website and file a request with the FCC to waive the deadline. The request for waiver should be filed in the FCC’s Electronic Comment Filing System with a citation to proceeding number 02-6. Your request should include a document explaining the circumstances leading to the late submission of your FCC Form 471 and a request for waiver of the FCC Form 471 filing deadline. The FCC’s Electronic Comment Filing System is located at this website: https://www.fcc.gov/ecfs/filings.

California Funding Commitment Summary

Funding Year 2020

As of April 26, 2020, California applicants have successfully submitted 6,582 funding requests for $263 million. Of these requests, 29% are in Wave Ready or Final Review status, 49% are for Category 1 services, and 51% are for Category 2 services.

Funding Year 2019

California applicants submitted over 8,000 funding requests in FY2019 for over $358 million. To date, USAC has issued commitments for 7,794 of these requests for a total of $305 million.

Pending Dates and Deadlines

Funding Year 2018 Non-Recurring Services Extended Invoice Deadline

In general, the deadline for invoicing USAC for FY 2018 non-recurring services was January 28, 2020. Applicants and service providers that requested and were approved for the single one-time 120-day extension now have an invoice deadline of May 27, 2020. Per the Novel Coronavirus Disease 2019 (COVID-19) Order, the FCC has now granted an additional 120-day extension to September 24, 2020. We encourage applicants, if they are able, to continue to try and meet invoice deadlines so as to not delay receipt of E-rate funding.

Funding Year 2019

FCC Form 486 must be filed 120 days from the date of the issuance of the Funding Commitment Decision Letter (“FCDL”) or the start date of E-rate eligible services, whichever is later. For ongoing recurring services, starting on July 1, 2019, the following deadlines have passed or are approaching in the next month.

Waves #

FCDL
Date

Form 486 Due Date

Extended COVID-19 Due Date*

1-32

04/27/2019-
11/07/2019

Deadline passed for services starting 07/01/2019

N/A

34

11/21/2019

3/20/2020

7/18/2020

35

11/27/2019

3/26/2020

7/24/2020

36

12/5/2019

4/3/2020

8/1/2020

37

12/12/2019

4/10/2020

8/8/2020

38

12/19/2019

4/17/2020

8/15/2020

39

12/27/2019

4/25/2020

8/23/2020

40

1/2/2020

5/1/2020

8/29/2020

41

1/9/2020

5/8/2020

9/5/2020

42

1/16/2020

5/15/2020

9/12/2020

43

1/23/2020

5/22/2020

9/19/2020

44

1/30/2020

5/29/2020

9/26/2020

*For FCC Form 486 deadlines that fall between March 11, 2020 and September 30, 2020, the FCC directed USAC to provide applicants with an additional 120 days to submit these forms without penalty.

Funding Year 2018

FCC Form 486 must be filed 120 days from the date of the issuance of the Funding Commitment Decision Letter (FCDL) or the start date of E-rate eligible services, whichever is later. For ongoing recurring services, starting on July 1, 2018, the following deadlines have passed or are approaching in the next month.

Waves #

FCDL
Date

Form 486 Due Date

Extended COVID-19 Due Date*

1-68

04/20/2018-
11/04/2019

Deadline passed for services starting 07/01/2018

N/A

70

11/18/2019

3/17/2020

7/15/2020

71

11/25/2019

3/24/2020

7/22/2020

72

12/2/2019

3/31/2020

7/29/2020

73

12/9/2019

4/7/2020

8/5/2020

78

1/13/2020

5/12/2020

9/9/2020

*For FCC Form 486 deadlines that fall between March 11, 2020 and September 30, 2020, the FCC directed USAC to provide applicants with an additional 120 days to submit these forms without penalty.

Applicants missing these or earlier deadlines should closely monitor their News Feed in the E-rate Productivity Center for an FCC Form 486 Urgent Reminder Letter notification. This letter will allow the applicant a 15-day extension to submit an FCC Form 486 without penalty.

E-rate Training Resources

Applicants may access multiple recordings and other supporting material at the following websites.

E-rate Process: Activities to Work on Now

Respond to Universal Service Administrative Company Program Integrity Assurance Review

All FCC Form 471 applications undergo Program Integrity Assurance (PIA) review by the program administrator, USAC. In some instances, USAC reviewers may reach out to the Contact person listed on the FCC Form 471 to ask questions about the application and/or request documentation to substantiate the eligibility of services, the eligibility of entities receiving services, and the data used to calculate the E-rate discount. While responses to USAC’s questions are submitted in the applicant’s E-rate Productivity Center (EPC) portal, the outreach from USAC will be sent to the Contact’s e-mail address. Applicants have an initial 15 days to respond to USAC’s request for information. Due to COVID-19, the FCC has directed USAC to grant automatic 30-day extensions to all PIA deadlines. Further, if applicants are unable to respond to USAC's inquiries due to school closures or other circumstances due to COVID-19, USAC will not deny applications, but may indefinitely defer review on them until the applicant is able to respond. Non-response to USAC’s questions may lead to delays in receipt of funding commitment decision letters. If you are able, respond to USAC’s questions by the stated deadline or contact your USAC PIA reviewer to give USAC a status of when you may be able to respond to USAC's questions.

How are Applicants notified of PIA Inquiries?

The PIA reviewer will send an email to the FCC Form 471 Contact to let them know that questions are available through the EPC News Tab.

The notification in the EPC News tab will include:

Today's date

Response due date

Contact name

Applicant name

FCC Form 471 application number

A brief description of the question or questions

Your PIA reviewer's name and telephone number

A hyperlink to your questions (the blue bar at the bottom of the notification)

How do Applicants view and respond to PIA Inquiries?

The EPC News item will include a hyperlink to the application that will take applicants to the application Summary page of the associated FCC Form 471. To view a complete list of PIA inquiries applicants must then navigate to the Review Inquiries page.

If applicants submitted more than one FCC Form 471 that requires PIA review, they will receive a separate set of questions for each form. Make sure to respond to all inquiries/questions on each FCC Form 471.

Applicants can perform the following actions from the Review Inquiries page by following the menu options on the top of the page:

When responding to inquiries, applicants will see two-page sub-menus: Pending Inquiries and Submitted Inquiries.

Pending Inquiries will include the list of any pending inquiries, the read status, the outreach type, the reviewer’s name and contact information, the date the inquiry was issued, the date inquiry is due, and inquiry status. When selecting individual inquiries, applicants have the ability to view the individual question and upload supporting documentation. Please note: Only one user can work on an inquiry at a time. Users must Save and Close out of inquiries for other to access the inquiry. When applicants are satisfied with the drafted response and any supporting documentation, if any, they must click Submit to send the response to the inquiry.

Submitted Inquiries are responses that have been submitted to the PIA reviewer.

How do Applicants request an extension of time to respond to PIA Inquiries?

Applicants may request more time to respond to PIA inquiries while they gather necessary information. When extension requests are submitted in EPC, applicants will automatically be granted the first request and, per the COVID-19 Order, will receive an additional 30 days to respond. Applicants are encouraged to call or e-mail their assigned PIA reviewer if there are special circumstances that will necessitate additional time. If the PIA reviewer is unresponsive, open a customer service case in EPC, or call USAC at (888) 203-8100.

The FCC has initiated multiple response measures to support our nation’s schools in their response to COVID-19.

Waiver of Various E-rate Filing Deadlines

In recognition of the unprecedented impact on schools due to the COVID-19 pandemic, the FCC has waived and extended multiple E-rate deadlines as described below.

(1)Service delivery deadline for non-recurring: Any funding requests for non-recurring services with a September 30, 2020 deadline will receive an automatic extension to September 30, 2021. This primarily impacts the installation deadline for Category 2 Internal Connections and installation of Category 1 broadband services.

(2) Installation deadline of Category 1 special construction: The FCC requires that service is delivered and lit by June 30 of the funding year for funding requests that include one-time special construction of Category 1 broadband services, allowing for a single one-time, one-year extension request. The FCC has automatically extended the deadline for any special construction funding requests with a June 30, 2020 deadline to June 30, 2021.

(3) Appeal deadline: FCC rules require parties seeking review or waiver of a decision by the Universal Service Administrative Company (USAC), either directed to USAC or the FCC, to submit their requests within 60 days from the date of the decision. This deadline has been extended to 120 days. This waiver will be in effect for parties seeking review or waiver of an adverse USAC decision with an appeal deadline between March 11, 2020 and September 30, 2020.

(4) Invoice filing deadline: The FCC will provide all applicants and service providers with an automatic 120-day extension of the invoice filing deadline for any funding request with an invoice deadline between March 11, 2020, and October 28, 2020.

(5) FCC Form 486 deadline: The FCC Form 486 deadline is 120 days from USAC’s issuance of the Funding Commitment Decision Letter, or 120 days from the start of service, whichever is later. For FCC Form 486 deadlines that fall between March 11, 2020 and September 30, 2020, the FCC directs USAC to provide these applicants with an additional 120 days to submit these forms without penalty.

(6) USAC review deadlines: The FCC also directs USAC to grant automatic 30-day extensions to the deadlines associated with USAC’s review of and outreach pertaining to the following forms and requests: FCC Form 471 Program Integrity Assurance (PIA), USAC appeals, invoices, FCC Form 500 requests, service substitutions, Service Provider Identification Number (SPIN) changes, funding request cancellation requests, and program audits.

Reminder to Schools that the Community May Access On-Campus WiFi When Schools are Closed

In 2010, the FCC lifted restrictions to enable for community use of E-rate funded broadband services on a school’s campus while school is not in session. On March 23, 2020, the FCC reiterated that allowing for community access of WiFi on a school’s campus while schools are closed due to the COVID-19 pandemic is allowed under current program rules. However, the FCC declined to address allowing for the expansion of a school’s WiFi network beyond the school’s property line which is currently disallowed by E-rate program rules. You may read the entire public notice at the FCC’s website, https://www.fcc.gov/document/community-use-e-rate-supported-wi-fi-permitted-during-closures.

Waiver of E-rate Gift Rules

As mentioned in our previous News Flash, the FCC announced that it is temporarily waiving the E-rate gift rules through September 30, 2020. Due to the necessity for schools to acquire goods and services to meet increased broadband demand or to support connectivity to students at home while schools are closed, the FCC is waiving E-rate program gift rules to enable service providers to offer, and E-rate eligible schools to solicit or accept, broadband connections, devices, networking equipment, or other things of value that could help students and teachers affected by school closures during the coronavirus pandemic. You may read the entire order at the FCC’s website https://www.fcc.gov/document/fcc-acts-support-telehealth-remote-learning-during-coronavirus.